GANADHIPATI CONSTRUCTION PRIVATE LTD,PATNA vs. PCIT, CENTRAL, PATNA

In the result, all the appeals of the assessee bearing

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

disallowance and deduction under section 80IA of the Act. Therefore, it cannot be said that the assessment has been completed without making proper inquiries or no inquiries. He also submitted that the draft assessment orders were sent to the ld. JCIT for granting approval under section 153D of the Act and the same was granted on 31.03.2022, which itself proves

GANADHIPATI CONSTRUCTION PRIVATE LIMITED,PATNA vs. PCIT, CENTRAL, PATNA

In the result, all the appeals of the assessee bearing

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

disallowance and deduction under section 80IA of the Act. Therefore, it cannot be said that the assessment has been completed without making proper inquiries or no inquiries. He also submitted that the draft assessment orders were sent to the ld. JCIT for granting approval under section 153D of the Act and the same was granted on 31.03.2022, which itself proves

GANADHIPATI CONSTRUCTION PRIVATE LIMITED,PATNA vs. PCIT, CENTRAL, PATNA

In the result, all the appeals of the assessee bearing

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

disallowance and deduction under section 80IA of the Act. Therefore, it cannot be said that the assessment has been completed without making proper inquiries or no inquiries. He also submitted that the draft assessment orders were sent to the ld. JCIT for granting approval under section 153D of the Act and the same was granted on 31.03.2022, which itself proves

GANADHIPATI CONSTRUCTION PVT LTD,PATNA vs. PCIT, CENTRAL, PATNA

In the result, all the appeals of the assessee bearing

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

disallowance and deduction under section 80IA of the Act. Therefore, it cannot be said that the assessment has been completed without making proper inquiries or no inquiries. He also submitted that the draft assessment orders were sent to the ld. JCIT for granting approval under section 153D of the Act and the same was granted on 31.03.2022, which itself proves

M/S MANISH FINLEASE (P) LTD,PATNA vs. ITO, WARD-2(1), PATNA

Bench: Shri Chandra Mohan Garg & Laxmi Prasad Sahuassessment Year : 2010-2011 Manish Finlease Pvt Ltd., Vs. Ito, Ward 2(1), Patna Chandi House Exhibition Road, Patna Pan/Gir No.Aaccm 6252 B (Appellant) .. ( Respondent) Assessee By : Shri A.K.Rastogi & Rakesh Kumar, Ars Revenue By : Shri Indrajeet Singh, Dr Date Of Hearing : 20/06/ 2019 Date Of Pronouncement : 09/08/ 2019 O R D E R Per Bench This Is An Appeal Filed By The Assessee Against The Order Of The Cit(A)-1, Patna Dated 27.9.2018 For The Assessment Year 2010-2011. 2. The Appeal Filed By The Assessee Is Delayed By 51 Days. The Assessee Has Filed Application For Condonation Of Delay Stating The Reasons For Not Filing The Appeal In Time Before The Tribunal. After Hearing The Submissions Of The Parties, We Are Satisfied That The Assessee Had A Bonafide Reason For Not Filing The Appeal In Time. Therefore, We Condone The Delay & Proceed To Decide The Appeal Of The Assessee On Merits.

disallowed the said amount on the ground that mere establishing the identity of the creditor or the transaction have been routed through banking channel is not enough to prove the creditworthiness and genuineness of the transaction. On appeal, the CIT(A) called for remand report from the Assessing officer and after considering the same confirmed the addition. However, the Tribunal

MOTOR MACHINERUY TOOLS,PATNA vs. ACIT, CIRCLE-5, PATNA

In the result, the appeal filed by the assessee is partly allowed

Bench: Shri P.M. Jagtap, Vice-(Kz)]

43(1) of the Act and not by Section 28(iv) of the Act. I, therefore, delete the addition made by the AO u/s 28(iv) of the Act and confirmed by the ld. CIT(A) and allow ground no. 1 of the assessee’s appeal. 5. The issue in ground no. 2 relates to the disallowance

ACIT, CENTRAL CIRCLE-3, PATNA vs. BROADSON COMMODITIES PVT LTD, DHANBAD

In the result, both the appeals of Revenue are dismissed, whereas the Cross Objections filed by the assessee are allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

43,02,386/-. Assessment Years: 2016-2017 & 2017-2018 & C.O. Nos. 1 & 2/PAT/2022 (in ITA 62 & 63/PAT/2021) Assessment years: 2016-2017 & 2017-2018 Broadson Commodities Pvt. Limited 6. The ld. Assessing Officer has issued notices under section 143(2) and 142(1) in both the years. In A.Y. 2016-17, ld. Assessing Officer has observed that a perusal

ACIT, CENTRAL CIRCLE-3, PATNA vs. BROADSON COMMODITIES PVT LTD, DHANBAD

In the result, both the appeals of Revenue are dismissed, whereas the Cross Objections filed by the assessee are allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

43,02,386/-. Assessment Years: 2016-2017 & 2017-2018 & C.O. Nos. 1 & 2/PAT/2022 (in ITA 62 & 63/PAT/2021) Assessment years: 2016-2017 & 2017-2018 Broadson Commodities Pvt. Limited 6. The ld. Assessing Officer has issued notices under section 143(2) and 142(1) in both the years. In A.Y. 2016-17, ld. Assessing Officer has observed that a perusal

DCIT, CIRCLE-1, MUZAFFARPUR vs. M/S UTTAR BIHAR GRAMIN BANK, MUZAFFARPUR

In the result, the appeal filed by the Revenue is partly allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

43,67,25,641/- and disallowance of the provisional expenditure as per para 11 of the assessment order at ₹44,70,128/- were made and the total income was assessed at ₹176,92,74,630/-. Aggrieved with the assessment order, the assessee filed an appeal before the Ld. CIT(A) who considered in detail the provisions of section 36(1

DCIT, CIRCLE-1, MUZAFFARPUR vs. M/S UTTAR BIHAR GRAMIN BANK, MUZAFFARPUR

In the result, the appeal filed by the revenue is dismissed

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey] I.T.A. No. 29/Pat/2021 Assessment Year: 2013-14 Dcit, Circle-1, Muzaffarpur M/S Uttar Bihar Gramin Bank

1)(viia) of Rs. 18,99,43,632/- is allowed.” 9. Keeping in view the above discussion and the order passed by the CIT(A), we do not find any infirmity in the order of Ld. CIT(A) on the aforesaid issue i.e. the disallowance made under this head amounting to Rs. 10,70,70,590/- 10. Coming

ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, MUZAFFARPUR, MUZAFFARPUR vs. AJIT KUMAR, BETTIAH

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri George Mathan & Shri Rakesh Mishra

1. The assessee at the time of hearing before CIT(A) had submitted in respect of the disallowance u/s 40A(3) as below:- “In respect of the additions on account of application of Section 40A(3) on the cash payment entries of, out of books purchases and sales recorded in I.T.A. No.: 239/PAT/2024 Assessment Year: 2017-18 Ajit Kumar

ACIT, CENTRAL CIRCLE-1, PATNA vs. SONAMOTI AGROTECH PVT LTD, PATNA

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

43 of the paper book. He also drew our attention towards inventory of cash found during the course of search, details are available on page 44 and inventory of stock found is available on page 45 (Annexure A/3). On the strength of these details, he pointed out that the evidence regarding bogus share 9 Assessment Year

DIVYA PRAKASH,BHOJPUR vs. PR. CIT-1, PATNA

In the result, the appeal of the assessee is dismissed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

1) was issued and served to the assessee. In response to the notice Sri Rajiv Ranjan, adv and the assessee himself appeared to represent the case. During the course of proceedings it was submitted that the assessee is engaged in the business of sale of liquor . The assesee was asked to produce statement of all bank account, all books

ZAIMUR RAHMAN,EAST CHAMPARAN vs. INCOME TAX DEPARTMENT, NFAC, DELHI

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

1) passed under Section 147 read with Section 144B of the Act for the Assessment Year 2015-16, by the ld. assessing officer at Assessment Unit, Income Tax Department, is bad both in law and on facts. 4. For that the appellant was not given any opportunity, much less sufficient opportunity, to put forth his contentions and place evidences henceforth

UTTAR BIHAR GRAMIN BANK,MUZAFFARPUR vs. DC/AC CIRCLE-2, MUZAFFARPUR

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.186/Pat/2025 Assessment Year: 2016-17 Uttar Bihar Gramin Bank……….....…..…………………....Appellant Sharma Complex, Ramna Kalambagh Chowk, Muzaffarpur, Bihar – 842002. [Pan: Aaaju0238J] Vs. Dc/Ac, Circle-2, Muzaffarpur.……….…............................…..…..... Respondent Appearances By: Shri Sanjeev Kr. Anwar, Advocate, Appeared On Behalf Of The Appellant. Shri Rajat Datta, Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 22, 2025 Date Of Pronouncing The Order : July 23, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal Has Been Filed By The Assessee Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals), Patna ["Cit(A)"] For The Assessment Year 2016-17. 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income Declaring A Total Loss Of Rs.47,24,77,982. The Case Was Selected For Scrutiny Under Compulsory Manual Selection Criteria During The Financial Year 2017-18. Accordingly, Statutory Notices Under Sections 143(2) & 142(1) Of The Income-Tax Act, 1961 ("The Act") Were Issued & Duly Served Upon The Assessee. In Response, The Assessee Appeared & Made Certain Submissions. However, The Assessing Officer Made The Following Additions/Disallowances: Rs.16,84,20,016: Provision For Npa.

section 36(1)(va) as not deposited before the due date. After the above disallowances, the total income of the assessee was assessed at Rs.1,43

LAL BABU PRASAD,SIWAN vs. ACIT, CIRCLE-2, MUZAFFARPUR

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER SHRI SONJOY SARMA (Judicial Member)

sections 143(2) and 142(1) of the Act were issued. On the basis of the submissions made by the assessee, a discrepancy in stock was identified at ₹3,25,06,633. After deducting the opening stock of ₹49,68,567, the net discrepancy was worked out. During the assessment proceedings, the assessee voluntarily declared additional income

ACIT, CIRCLE-4, PATNA vs. KUMAR ARUNODAYA, PATNA

In the result, the appeals of the assessee are allowed, the appeals of the revenue is dismissed and the Cross-objections of the assessee are also dismissed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

43,27,813/- for sale of land of M/s Chandramauli Developers Pvt. Ltd. has not materialized as the cheque issued by the said party were not honoured and therefore sale deed became invalid and was cancelled and consequently no capital gain was shown in the return of income. Therefore even on merit the revenue has no case

DCIT, CIRCLE-4, PATNA vs. KUMAR ARUNODAYA, PATNA

In the result, the appeals of the assessee are allowed, the appeals of the revenue is dismissed and the Cross-objections of the assessee are also dismissed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

43,27,813/- for sale of land of M/s Chandramauli Developers Pvt. Ltd. has not materialized as the cheque issued by the said party were not honoured and therefore sale deed became invalid and was cancelled and consequently no capital gain was shown in the return of income. Therefore even on merit the revenue has no case